We make every effort to ensure the data presented here is accurate based on the best available information currently on file with DEC. It is therefore subject to change as new information becomes available. We recommend contacting the assigned project staff prior to making decisions based on this information.

Problems/Comments

The Dry Well was used from the 1950s through the early 1990s. Operations performed at the POL laboratory include analysis of various fuels such as motor gas, aviation fuel, JP4, and arctic-grade diesel for quality assurance purposes. Spent reagants, solvents, heavy metals, residual fuels left over after testing were disposed in a dump sink that was connected to the dry well.
The drywell was approximately 15 feet from the southeast side of Building 986, 4 feet in diameter, and approximately 15 feet deep. Soil contamination found from various fuels including jet fuel during site investigation.
Army has removed contaminated soil from the site to the maximum extent practicable and no further remedial action is required. FTRS-09 Bldg. 986 POL Dry Well and FTRS-10 Bldg 986 UST 44 ER,A Eligible Response Complete. Site# W020, 1990 RFA SWMU 60. Originally OUA originally consisted of three sites: the Roosevelt Road Transmitter Site Leachfield; the Petroleum, Oil, and Lubricant Lab Dry Well; and the Ruff Road Fire Training Area.
Fort Richardson-Proposed NPL Listing Date 6/23/1993
FEDERAL REGISTER NOTICE of Final NPL Listing Date 5/31/1994
RCRA Handler ID AK 1210022157. UST Facility ID 788. EPA ID: AK6214522157.

Action Information

Action Date

Action

Description

DEC Staff

11/12/1940

Update or Other Action

A letter from the War Department Adjutant General's Office to Commanding Generals of all Armies, with a First Indorsement from Headquarters Ninth Corps Area, Presideo of San Francisco, CA, to Commanding Officers all Army Posts, dated 12 November 1940, stated that the Army Post near Anchorage, Alaska, known as Elmendorf Field was designated as Fort Richardson, Alaska, and the air field was designated as Elmendorf Field, Alaska.

Jennifer Roberts

12/12/1940

Update or Other Action

War Department General Order no. 9, dated 12, December 1940, announced that the military reservation located near Anchorage, Alaska, was designated as a permanent military post under the provisions of AR 210-10 and was designated Fort Richardson in honor of Brigadier General Wilds P. Richardson, US Army. The flying field at Fort Richardson, AK, was designated "Elmendorf Field" in honor of Captain Hugh M. Elmendorf, A.C., who was killed in an airplane accident in the vicinity of Wright Field, OH on 13 January 1933.

Jennifer Roberts

3/3/1951

Update or Other Action

Elmendorf Air Force Base was transferred from the Department of Army to the Department of the Air Force on this date. Transfer of all property in place was authorized.

Jennifer Roberts

1/25/1988

Update or Other Action

USEPA Assistant Administrator J. Winston Porter (OSWER) Memorandum for the record to Regional Administrators I-X Subj: Enforcement Actions under RCRA and CERCLA at Federal Facilities.
Statutory language makes it clear that Federal facilities must comply both procedurally and substantively with RCRA and CERCLA in the same manner as any non-Federal entity. The purpose of this memo is to lay out the statutory authorities under RCRA and CERCLA that EPA may use at Federal facilities to achieve compliance and expeditious cleanup.
EPA (The Agency) is viewing the Section 120 Interagency agreement as a comprehensive document to address hazardous substance response activities at a Federal facility from the remedial investigation/ feasibility study (RI/FS) through the implementation of the remedial action. All such interagency agreements must comply with the public participation requirements
of Section 117.
The timetables and deadlines associated with the RI/FS and all terms and conditions associated with the remedial actions (including operable units or interim actions) are enforceable by citizens and the States through the citizen suit provisions of Section 310 of CERCLA. In addition, Section 122(1) of CERCLA authorizes the imposition of civil penalties against Federal agencies for failure to comply with interagency agreements under Section 120. Procedures for imposing these penalties are provided for in Section 109 of CERCLA.
Executive Order 12580 clarifies that EPA is authorized to issue Section 104 and Section 106 administrative orders to other Federal agencies, with the concurrence of the Department of
Justice. Section 4(e) of the Executive Order provides that: Notwithstanding any other provision of this Order, the authority under Section 104(e)(5)(A) and Section 106(a) of the Act to seek information, entry, inspection, samples or response action from Executive Departments and agencies may be exercised only with the concurrence of the Attorney General.
States also have a variety of enforcement authorities under CERCLA, so the exercise of EPA's enforcement authorities should be closely coordinated with the States.
First, Section 121(e) (2) of CERCLA authorizes States to enforce ANY Federal or state standard, requirement, criteria or limitation to which the remedial action must conform under CERCLA.
Second, Section 310 authorizes citizen suits to require Federal agencies to comply with the standards, regulations, conditions, requirements, or orders which have become effective pursuant to CERCLA including IAGs under Section 120 of the Act.
Third, Section 120(a)(4) clarifies that State laws concerning removal and remedial action, including State laws regarding enforcement, are applicable at Federal facilities not included on the NP. In addition, Section 120(i) states that nothing in CERCLA Section 120 shall affect or impair the obligation of the Federal agency to comply with the requirements of RCRA, including corrective action requirements (see section IV.C., "Importance of the States as a Party to the IAG"). EPA enforcement actions against Federal agencies should therefore be carefully coordinated with States to avoid potentially duplicative or conflicting exercises of authority.
All RCRA Subtitle C permits issued after November 8, 1984, will contain provisions for implementing the corrective action requirements of 40 CFR Part 264 Subpart F (or authorized state requirements), and Section 3004(u) and (v) of RCRA. For facilities that have or are seeking a RCRA permit, the requirements for a "CERCLA" remedial investigation and cleanup could be met by implementing these requirements through RCRA corrective action.
It is important to keep in mind, however, that the extent of coverage of the RCRA permit is generally limited to hazardous wastes/constituents (e.g., some CERCLA hazardous substances such as radionuclides are not RCRA hazardous constituents and, therefore, the permit may not be able to address all of the releases at a facility).
The corrective action authority under Section 3008(h) of RCRA can be used at RCRA interim status facilities to address releases from RCRA regulated units and other solid waste management units. At a Federal facility that has interim status, a RCRA corrective action order could address the investigation and clean-up of releases in. lieu of a "CERCLA" response action or as an interim measure. Again, the extent of coverage in the RCRA corrective action order is limited to RCRA hazardous wastes/constituents.)
CERCLA Section 106 can be used to address releases from RCRA units or CERCLA sites when an "imminent and substantial endangerment" is shown. A Section 120 IAG could be drafted to incorporate all RCRA corrective action requirements and CERCLA statutory requirements. Where some or all of a Federal installation has been listed on the NPL, the CERCLA Section 120 IAG is required for remedial action by statute.

Louis Howard

5/8/1990

Report or Workplan Review - Other

ADEC sent Col. Edwin Ruff letter re: USTs at Fort Richardson. Staff reviewed the draft SOPs for Site Investigation of UST removals dated April 11, 1990.
Screening Method: Soil samples collected when HNU [photoionization analyzer] readings are consistently less than 50 ppm. Recommend excavating until the readings with Hnu are non-detectable (or equal to the background readings) and then collecting soil samples for laboratory analysis.
Sample location: The department has not been accepting composite sampling from within excavation as a means of determining adequacy of cleanup. Composite sampling has been approved as a method of characterizing spoils piles after excavation.
Sample collection procedure: Sample collection jars should be obtained from the laboratory that will perform the analyses. Samples must be stored at 4 degrees celsius from the time of collection until analyzed (within 14 days of collection).
Analysis: All soil samples should be analyzed for Total Petroleum Hydrocarbons (EPA Method 418.1) and BTEX (EPA Method 8020) unless a hydrocarbon identification test (EPA Method 8015) clearly shows that the contamination is ONLY diesel or another non-gasoline fraction hydrocarbon such as heating fuel. Under these conditions, samples need only be analyzed for TPH.
If the tank was used for waste oil, soil samples should be analyzed for PCBs (EPA 8080), total arsenic, cadmium, chromium, and lead as proposed in your SOPs. If the total lead content is above allowable limit, additional sampling and analysis should be conducted following the toxic characteristic leaching procedure (TCLP). Rather than testing the soils for total organic halides by EPA Method 9020, the department is requesting analysis of total organic halides by EPA Method 8010.
If a site cannot be cleaned up adequately through the tank removal and initial excavation efforts, a site assessment may be requested including individual work plans and QA/QC plans. For the initial tank removals this letter and your SOP for tank removals, dated April 11, 1990, will suffice as a generic work plan.

Ron Klein

9/26/1990

Update or Other Action

INTERIM GUIDANCE FOR SURFACE AND GROUNDWATER CLEANUP LEVELS SEPTEMBER 26, 1990
Interim cleanup guidance for contaminated surface and groundwater remediation is necessary to ensure that consistent cleanup levels are being applied by district and regional program staff. The following guidelines should be implemented under 18 AAC 75.140 which specifies that a "discharge must be cleaned up to the satisfaction of the Regional Supervisor or his designee.
Final cleanup levels shall be determined by the Regional Supervisor or his designee based on site-specific conditions. Staff should be aware that if a facility is regulated under RCRA, that RCRA corrective action and cleanup standards should enter into development of final site cleanup levels.
Groundwater should be cleaned up to levels not exceeding the more stringent of the final State or Federal Maximum Contaminant levels (MCLs) for Organic and Inorganic Chemicals. If final MCLs have not been adopted for a contaminant, then groundwater should be cleaned up to levels not exceeding proposed Federal MCLs. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned, up to non-detectable levels as measured by EPA Method 418.1.
Final State MCLs are specified in 18 AAC 80.050 and final Federal MCLs are specified in 40 CFR 141 and 142. Proposed Federal MCLs are specified in the May 22, 1989, Federal Register Vol. 54, No. 97, pages 22155 - 22157 and the July 25, 1990, Federal Register Vol. 55, No. 143, pages 30408 - 30448. Appendix I provides a summary listing of State and Federal Final and Proposed MCLs for selected organic and inorganic contaminants.
For organic and in organic contaminants that have not been assigned a final or proposed MCL, cleanup levels should be based on criteria cited in EPA's Water Quality Criteria. 1986 using a health risk factor of 10-6. EPA's water quality criteria identify concentrations of elements and compounds which have toxic effects on aquatic organisms or toxic and carcinogenic effects on humans.
If groundwater is being used as a drinking water source and alternative water supplies or point of use water treatment cannot be provided, then final or proposed secondary maximum contaminant levels (SMCLs) may be used as cleanup target levels. SMCLs are based on aesthetic properties such as taste and odor, whereas MCLs are based on human health risks. For compounds such as xylenes, the SMCL maybe several hundred times lower than the MCL.
Surface waters used for drinking water should also be cleaned up to levels not exceeding the final or proposed MCLs for organic and inorganic chemicals, as specified above. Under the authority of 18 AAC 70.020, surface waters important to the growth and propagation of aquatic life should be cleaned up to the listed criteria which includes EPA's Water Quality Criteria. 1986. These criteria identify concentrations of specific elements or compounds which have toxic effects on aquatic organisms. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned up to non-detectable levels as measured by EPA Method 418.1.
Alternative Cleanup Levels (ACLs) may be adopted for a site if a risk assessment approved by the department is performed and cleanup to levels identified above is technically infeasible. Risk assessments will not by themselves establish ACLs. Determination of cleanup levels is a risk management decision that the department must make based on results of a quantitative risk assessment and other pertinent information.
The responsible party (RP) may prepare at its own expense a risk assessment which shall include an assessment of both human health and environmental risks. Specific components of the risk assessment should include an exposure assessment, toxicity assessment, risk characterization, and justification of ACLs. A general description of these risk assessment components is provided in Appendix II.
General technical requirements for risk assessments should be based on EPA risk assessment guidance for superfund sites. A site specific risk assessment procedure must be prepared by the RP and submitted to the department for review and approval prior to conducting a risk assessment. The RP, at the department's discretion, must agree to reimburse the department for expenses incurred by the department if it chooses to contract for a risk assessment review.

Louis Howard

10/31/1990

Update or Other Action

Soil quality assessment for building 986. Prior to the installation of the new underground storage tank system (UST), Brown & Root Services Corporation has requested an environmental soil quality assessment be performed to evaluate whether the activities associated with the existing UST and the dry well have had an impact on the soil at the proposed new UST location.
Boring TB-1 was positioned midway between the existing UST and the proposed UST site. Boring T3-2 was placed adjacent to the proposed UST location. Closest location of the borings was about 50-55 feet away from the dry well and existing UST drilled to a depth of 21.5 feet bgs.
After sampling, analytical samples were collected by quickly and completely filling laboratory provided teffon lidded gIass jars. All samples were transferred from the sampler to the jars using a decontaminated stainless steel spoon. A total of 4 soil samples from each boring were sent to the laboratory for analytical testing.
For this project,--eight soil samples were selected for analysis to characterize the in-place soils for potential contamination by petroleum hydrocarbon constituents, selected metals and chemicals. These samples were analyzed for total petroleum hydrocarbons (EPA 418.1), halogenated volatile organics (EPA 8010), aromatic volatile organics (EPA X020), pesticides and PCBs (EPA SO&O), and for heavy metals (EPA 7000 Series). The metals tested include arsenic, cadmium, chromium, lead, mercury, and silver. All samples were analyzed by Chemical & Geological Laboratories, Inc.
As evidenced by the analytical laboratory test results, low levels of petroleum hydrocarbon
constituents were found in the samples analyzed. The upper limit of total petroleum hydrocarbon
(TPH) concentration, 35.9 ppm (mg/kg), was found in Sample TBlSl taken from 2.5 to 4.0 feet
in Boring TB-1.
The laboratory analyses for selected metals and waste chemicals were either in the realm of
background levels for similar type soils or non-detected. Arsenic, cadmium, total chromium, and
lead concentrations ranged from 4.9 to 9.9 ppm, 0.08 to 0.17 ppm, 35.2 to 50.1 ppm, and 5.3 to
8.9 ppm, respectively. Mercury and silver were not detected in the samples analyzed.
Concentrations of aromatic volatile organics, halogenated volatile organics, pesticides, and PCBs were non-detectable in all thk soil samples analyzed.
The data shows contamination was not found exceeding level "A" criteria.

Louis Howard

2/4/1991

Report or Workplan Review - Other

U.S. Army Engineer District workplan for sampling analysis and quality assurance/quality control (QA/QC) Plan, health and safety plan sent to ADEC for review. Fifteen (15) comments included in letter from Rich Sundet (DEC) to C. Fosbrook Environmental engineer on workplan submitted.

Rich Sundet

4/5/1991

Enforcement Agreement or Order

RCRA Federal Facility Compliance Agreement was entered into pursuant to RCRA, and executive order 12088, Federal Compliance With Pollution Control Standards (43 Fed Reg. 47707, October 13, 1978). Refer to Docket # 1090-05-29-6001 and EPA ID # AK1210022157.
The proceeding was initiated by a Notice of Noncompliance dated June 19, 1990, issued pursuant to the Solid Waste Disposal Act, as amended, also known as the Resource Conservation and Recovery Act, 42 USC 6901 et seq. RCRA. On 6/8-9 1989 an inspection by EPA and ADEC of the Post to determine its compliance status with RCRA, the Army failed to determine if its waste was a HW at 986.
April 30, 1991 inspection of building 986 revealed in the AOAP room, the POL Lab was operating a hazardous waste container storage facility without interim status or a permit, in violation of 40 CFR 262.34(b). There were no accumulation start dates on any of the containers, nor were any of the containers labeled "hazardous waste," in violation of 40 CFR 262.34(a). This area was not inspected at least weekly, in violation of 40 CFR 265.174 and paragraph 21.B in the FFCA.
Outside of the building, five drums, in deteriorating condition and with considerable amounts of gravel on them, with unknown contents were present. Fort Richardson failed to make an adequate hazardous waste determination on the contents of the drums in violation of 40 CFR 262.11 and paragraph 21.A of the FFCA. The drum storage practices at building 986 are a violation of 40 CFR 262.34(b) for storage for greater than 90 days without a permit or interim status. The facility continues to fail to inspect this area at least weekly in violation of 40 CFR 265.174 and paragraph 21.B. of the FFCA.
Required compliance action- Fort Richardson shall determine if its waste located at building 986 is a hazardous waste and comply with 40 CFR 262.11. Fort Richardson shall obtain a detailed chemical and physical analysis of a representative sample of waste or use knowledge of the waste to determine if wastes are hazardous wastes, as required by 40 DFR 262.11, 40 CFR 265.13(a)(1) and 40 CFR 268. On or before June 29, 1991, Fort Richardson shall submit closure/post closure plans for EPA approval, for tanks and containers at building 986 which meet the requirements of 40 CFR 265 SubPart G. Upon EPA approval of those plans, Fort Richardson shall implement the closure/post closure plans for building 986.

Louis Howard

6/12/1991

Site Visit

June 12, 1991 Resource Conservation & Recovery Act (RCRA) HW Management Compliance Evaluation Inspection Report documents Tim Law, Daniel Hartung, Vic Vickaryous, Geoffrey Kany, of ADEC's RCRA program inspection the Post for compliance with the provisions of the compliance agreement (FFCA) on April 29, April 30, 1991
On Tuesday, April 30 at 11:30 AM, the inspection team next inspected Building 986. Mr. Chuck Rider, a Quality Assurance Representative, escorted the inspection team through the POL Lab.
Mr. Ryder stated that only physical tests are done at this location anymore, that all of the chemical analysis is contracted out to DFSP. "POL" stands for Petroleum, Oil, and Lubricants."
The gentleman, Dan, who escorted the inspection team in May 1990, left in January 1991.
After analysis, JP-4 samples and any toluene and acetone used in the lab process formerly were poured down a "slop sink" and were collected in a 600 gallon (or 800 gallon, depending on the source of information) underground waste fuel tank behind Building 986. Since the May 1990 inspection, the operators ceased pouring fuel samples into the slop sink. Now after physical analysis, the jet fuel, diesel fuel, and MOGAS samples are collected in 5-gallon containers in the corner of the lab underneath the slop sink.
In the "AOAP Room", the POL Lab was operating a hazardous waste container storage facility without interim status or a permit, in violation of 40 CFR 262.34(b). See photos #14 & 15. There were no accumulation start dates on any of the containers, nor were any of the containers labeled as "hazardous waste," in violation of 40 CFR 262.34(a). This area was not inspected at least weekly, in violation of 40 CFR 265.174 and Paragraph 21.B. in the FFCA. A fire extinguisher was present, although it could not be determined what type of fire extinguisher it was. The bottles inside the cardboard boxes contained many glass bottle containing chemicals, including: sodium thiosulfate, potassium hydroxide, sodium nitrate, sodium carbonate anhydrous, glycerol/glycerin, methanol, naphtha solvent, chloroform, acetic acid, aniline solvent, nitric acid, and carbon tetrachloride.
Outside of Building 986 (see photos #16 & 17) remain five drums that were present during the May 1990 inspection. Mr. Ryder does not know what are in these five drums. The drums are not
labeled as to their contents. The drums are deteriorating. The drums have considerable gravel on them, which settled out of snow piles that bury these drums each winter from Fort Richardson's snow removal practices. These drums have clearly been abandoned. There is a chance that they contain acetone, solvents, used oil, contaminated fuel, or perhaps even freon, based on what the facility told the RFA team in June 1989.
Fort Richardson has failed to make an adequate hazardous waste determination on the contents of these drums, in violation of 40 CFR 262.11 and Paragraph 21.A. of the FFCA. The drum storage practices at Building 986 are a violation of 40 CFR 262.34(b) for storage for greater than 90 days without a permit or interim status. The facility continues to fail to inspect this area at least weekly, in violation of 40 CFR 265.174 and Paragraph 21.B. of the FFCA.
Out behind Building 986 is a hazardous waste fuel tank system which Fort Richardson has ceased placing hazardous waste or fuel into. See photos #16, 18, 19, & 20. The stacked blue drums in
photo #18 are empty. The two black 55-gallon containers in photo #19 contain auger cuttings. There were five such black 55-gallon containers filled with auger cuttings at the time of the
inspection.
Fort Richardson has failed to make an adequate hazardous waste determination on the contents of these drums, in potential violation of 40 CFR 262.11 and Paragraph 21.A. of the FFCA. This may just be a matter of poor timing for Fort Richardson, since Ms. Scott claims that they have been sampled and are awaiting analysis. Ms. Scott said that she is awaiting the analysis of the groundwater from these borings; and that she will assume the constituents in the groundwater analysis will be representative of what is in the auger cuttings when she makes a hazardous waste determination. Nonetheless, the containers are not marked with accumulation start dates, nor are labeled "hazardous waste," in violation of 40 CFR 262.34(a). These borings were installed by the Army Corps of Engineers.

The Corps conducted a previous investigation in November 1992. The objective of the 1992
investigation was to determine the presence and concentration of contaminants in the
POLLDW. During the investigation, water was observed at a depth of approximately 15 feet
BGS in the well. Approximately 18 inches of water covered a layer of sludge 6 to 8 inches
deep. The sludge contained approximately 80% water and fluid. Analytical results indicated that the water and sludge contained petroleum hydrocarbons and heavy metals, including arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver. Contaminants detected at the POLLDW during the 1992 investigation.

Louis Howard

1/26/1993

Update or Other Action

Army sent a letter via facsimile as in interim response to the compliance advisory letter dated January 6, 1993. The tank removal at 986 is being addressed in a letter to the Commander of the tenant organization for this facility (defense fuels support center). The Army is insisting on control of all environmental coordination and review of projects on the Post. They will provide ADEC with further information pertaining to action as it develops. Army requests an extension of the submittal deadline for the site assessment report to February 15, 1993.

John Halverson

2/1/1993

Update or Other Action

ADEC letter sent stating no objection to extending the submittal date for the site assessment at 986 to 2/15/93.

John Halverson

4/20/1993

Report or Workplan Review - Other

Staff reviewed and commented on the UST (#44) Site Assessment Building 986, POL laboratory, Fon Richardson, AK Prepared by the U.S. Army Corps of Engineers, Alaska District
We received the report referenced above on March 12, 1993. Unfortunately, the department cannot accept the report as meeting the minimum requirements for site assessment contained in Alaska's Underground Storage Tank Regulations (18 AAC 78.090).
The regulations clearly state, •... the collection of field data and the reponing of site
assessment data must be conducted by, or supervised by, a qualified, impartial third party, and
in accordance with an approved quality assurance program plan ... •. Based on information
submitted it is apparent that Oil Spill Consultants quality assurance program plan (QAPP) was
not followed. Furthermore, the report was prepared by the Army Corps of Engineers which
does not have an approved QAPP.
It is also apparent that additional site investigation is necessary to define the extent of
petroleum and chlorinated hydrocarbon contamination that was identified during installation of
soil borings in April of 1991.
The department requests a written response, by not later than May 21. 1993. identifying a
proposed time frame for conducting the necessary UST closure assessment and site investigation associated with the dry well.

John Halverson

4/27/1993

Report or Workplan Review - Other

Staff reviewed & commented on the Site Assessment report for UST removal, Ft Rich, Building 986, prepared by Oil Spill Consultants (OSC) & submitted 3-12-93
This letter is issued in response to our phone conversation on April 26, 1993 during which the site assessment report mentioned above was discussed. Unfortunately, there have been several deficiencies identified in the site assessment that was performed.
As noted in our letter of April 20, 1993, one issue of concern is that the report was not prepared in accordance with an approved QAPP. It was prepared by the COE, which does not have an approved QAPP on file with the department. The site assessment was performed by OSC & the report should have been prepared by them. In addition to this major problem, numerous other serious problems were noted with this site assessment. These are itemized below:
1. As required in regulation, & as stated in OSC OAPP, soils potentially contaminated with gasoline must be analyzed for BTEX. The report states that mixed products were present in the tank, including gasoline. However, these soils were not analyzed for BTEX, but instead only analyzed by "modified Method 8100" (used to detect levels of diesel range organics) & modified method 8015 (used to detect levels of gasoline range organics). Since the tanks were used to store gasoline, BTEX analyses should also have been performed. For this reason the site must be re-sampled using the correct analyses on the soils.
2. Given that the tank had contained different types of fuels, analyses for the full range of petroleum hydrocarbons should have been performed. The report indicated no analyses were conducted for residual range hydrocarbons as required by regulation & as stated in OSC's QAPP. Also, the reports of analyses conducted by Chemical & Geological Laboratories indicated that much of the chromatogram patterns were not consistent with middle range petroleum hydrocarbons. This provides further evidence that analyses for residual range petroleum hydrocarbons are required.
3. Previous site investigation work indicated the presence of chlorinated hydrocarbons in the soil, however, none of the samples collected during this site assessment were analyzed for chlorinated hydrocarbons. These additional analyses should be performed if there is indication of residual hydrocarbons in the soil.
4. On the Cooler Receipt Form, completed by Chemical & Geological Laboratories, item #12 states, "only one liter amber glass present for all of the sample." Based on this, it appears improper sample containers were used.
5. Collection of samples must be performed or supervised by qualified person listed on the firm's QAPP. The person who collected samples is not shown on OSC's QAPP as a qualified person; page 42 of OSC's QAPP states that samples are considered invalid if the samples were "collected when a qualified person was not on site conducting or supervising sample collection."
6. The site history contains no mention of the historical problems with the tank. The department has records of conversations with Ft Richardson Environmental Personnel which indicate conditions symptomatic of a leaking system.
7. No mention of field screening of samples is provided in the report. OSC's QAPP state that field screening will be conducted during site assessments. Filed screening is essential to conducting an adequate site investigation & collecting representative samples.
8. No mention is made of field screening or sampling associated with the piping trench, which OSC's QAPP states will be done.
9. No mention is made of the groundwater depth at the site. Regulations (18 AAC 7B.09O(d)(3)) require that if groundwater or the seasonal high water table is known or suspected to exist at a depth within five feet below the bottom of the UST, then at least one boring or test pit must be made & a sample collected from the first six inches of groundwater saturated soil or the zone of seasonal water table fluctuation. Since groundwater depth is not mentioned, it cannot be determined if a sample was required.
10. No mention is made of sampling the excavated soil stockpiled during removal of the UST. Standard industry practice & Oil Spill Consultant's QAPP states such sampling will be done.
11. The report does not provide the data deliverables that OSC's QAPP states will be provided. These data deliverables are also required by regulation.
12. The quality control analyses conducted by the Corps lab appeared to vary from accepted procedures. For example, Method 8015 requires extraction as soon as possible after collection & analysis within 14 days. The soil samples were collected on November 12, 1992, extracted on December 1, 1992 & analyzed on December 2. The holding times were significantly exceeded, rendering these quality control samples invalid.

Louis Howard

9/21/1993

Update or Other Action

A.G. letter (Breck Tostevin) to Tamela J. Tobia OS Judge Advocate for the Army. Letter states that a separate petroleum site compliance agreement should be separate from the CERCLA federal facility agreement. The petroleum site restoration agreement would function as a "two-party agreement" under the FFA. It would track the basic provisions of the UST Agreement but be tailored to the State's contaminated site regulations and would interface with the FFA. All petroleum sites addressed under the Two Party agreement would be reviewed in the final operable unit of the FFA and actions taken would be memorialized in a Record of Decision (ROD) under the FFA.

Louis Howard

11/12/1993

Enforcement Agreement or Order

State-Fort Richardson Underground Storage Tank Compliance Agreement signed by ADEC (Janice Adair Regional Administrator-Southcentral Office) and U.S. Army. The purpose of the agreement is to bring Fort Richardson into compliance with the Underground Storage Tank (UST) regulations and avoid the expense of formal enforcement proceedings.
The Army agrees to perform the necessary inventory, record keeping, registration, upgrading or closure, tightness testing, site assessment, release reporting, release investigation, and corrective action (remediation) associated with USTs at Fort Richardson (excluding Alaska Department of Military and Veterans Affairs and Army National Guard USTs). All petroleum sites addressed under the Two Party agreement would be reviewed in the final operable unit of the FFA and actions taken would be memorialized in a Record of Decision (ROD) under the FFA.
Site Assessment or Svstem Tightness Test
29. The Army shall conduct a site assessment* or a system tightness test, as required by AS 46.03.380(b) and 18 AAC 78.01S(i)(3), on all USTs located at Ft. Richardson, or permanently close the USTs in accordance with 40 CFR 280 and 18 AAC 78. If site assessments or system tests have been conducted, the Army shall submit proof of compliance by the deadlines set forth in the USTMP. Site Assessments or System Tightness Tests shall be conducted under the schedules in 18 AAC 78.015(i)(3) or, in order to come into compliance, as scheduled in the USTMP.
All tightness testing work will be conducted by a certified UST worker as required by 18 AAC 78.400. Site Assessment work will be conducted pursuant to 18 AAC 78 and an ADEC-approved Quality Assurance Program Plan (QAPP). With respect to UST recordkeeping requirements, the Army shall compile all required records by the date set forth in the USTMP and shall thereafter maintain and update those records as required by 18 AAC 78 and 40 CFR 280.
Release Investigation Reports
31. The Army shall submit to ADEC a Release Investigation* report for each UST site having a documented release* of petroleum products or hazardous substances. These reports will be submitted by the deadlines in the USTMP. The Release Investigation report shall contain all information required by 18 AAC 78.230(b), 18 AAC 78.240(c) and the following:
1) a detailed written or, if applicable, visual description of all work performed and summary of all pertinent data prepared by the Army and its consultants,
2) monitoring well construction data and
3) soil boring logs;
4) site maps detailing existing improvements and (if known)
5) the location of former fuel dispensing equipment,
6) water table elevation maps,
7) petroleum-product level and thickness (isoplot) maps,
8) organic-contaminant concentration maps,
9) aquifer interpretations,
10) other potential source areas within 1/4 mile,
11) data deliverables as outlined in 18 AAC 78,
12) interpretations of field observations and analytical data,
13) a completed Site Assessment/Release Investigation Summary Form, and
14) recommendations for any follow up work.
32. If upon review of a Release Investigation report the ADEC reasonably determines additional contamination assessment is required, ADEC shall notify the Army in writing. This writing will set forth the reason(s) the ADEC concluded that additional assessment is required.
111. "Site" shall mean a distinct area of contamination or potential contamination.
112. "Site assessment" shall mean the investigation of suspected contamination resulting from an unpermitted release of oil or hazardous substance as further defined in 18 AAC 78.090 (Site characterization and assessment).
110. "Release" shall have the meaning in AS 46.03.826 [(9) "release" means any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment, including the abandonment or discarding of barrels, containers, and other closed receptacles containing any hazardous substance.]
Listed in Attachment B as requiring a site assessment for UST 44.

Janice Adair

11/30/1993

Update or Other Action

Two monitoring wells were installed approximately 30 feet west of the dry wells in September and October 1993. The monitoring wells, installed by the Corps, were to provide information regarding contaminant migration from the POLLDW. Analytical results of groundwater samples collected from the monitoring wells are not yet available.

Louis Howard

6/30/1994

Update or Other Action

Origiinally proposed to the National Priorities List (NPL) on June 23, 1993, the Fort was added to the Unites States Environmental Protection Agency's (EPA's) NPL in June 1994. SUPERFUND SITE ID: 1001455 and CERCLIS EPA ID: AK6214522157.

Jennifer Roberts

8/1/1994

Report or Workplan Review - Other

Staff reviewed and commented on the Contract No. DACA85-93-D-0009 Delivery order No. 16 RI/FS Management Plan: Operable Unit A Fort Richardson. ADEC has no comments at this time on the
background information collection and review summary.

Louis Howard

8/5/1994

Report or Workplan Review - Other

Staff reviewed and commented on the Resubmittal of Site Assessment Report Building 986 Fort Richardson, AK
The Alaska Department of Environmental Conservation - Defense Facilities Oversight group (ADEC) has received, on July 25, 1994, a copy of the above referenced document. Below are our comments regarding the site assessment of UST 44.
5.2 Discussion page 11
The text states the site is recommended for closure and ADEC concurs based on the information presented in the document. Closing out this site does not preclude ADEC from requesting future remediation or site investigation at a later date. If new information indicates that previously undiscovered contamination or exposures lead to groundwater contamination above the applicable water quality criteria (18 AAC 70) or pose a risk to human health or the environment, then future investigation and/or remedial actions will be required by ADEC.
However, the dry well requires further action under OU-A and was subsequently transferred from the SFRERA for additional remedial investigation and remedial action.

Louis Howard

11/10/1994

Report or Workplan Review - Other

Staff reviewed and commented on the Contract No. DACA85-93-Da009 Delivery order No. 16 RI/F5 Management Plan: Operable Unit A-ARARs Fort Richardson October 1994.
ADEC concurs with the reasoning that the preliminary identification of applicable or relevant and appropriate requirements C4RARs) and other standards, criteria, and guidance “to be considered (TBC) at the RI/F5 scoping stage is helpful in guiding RI efforts. ADEC recognizes that the identification of ARM?s and TBCs is an iterative process to be conducted throughout the remedial investigation/feasibility study (RI/FS) stage of the CERCLA process.
ADEC also concurs with the reasoning if both federal and state laws address the same issues
which are applicable, appropriate and relevant, the more stringent or specific law has been cited to reduce redundancy. If a state regulation is applicable, but not listed in lieu of a parallel federal regulation, then a statement that the state regulation is not more stringent or more specific than the federal regulation is needed in the ARARs section.
2. Chemical-Specific ARARS beginning on page D-2-1
This section should list the following as chemical-specific ARARs:
1) Air Standards-40 CFR Pan SO National Primary and Secondary Ambient Air Quality Standards; 40 CFR Part 58 Ambient Air Quality Surveillance; 40 CFR part 60 Standards of Performance for New Stationary Sources; 40 CFR Part 61 National Emissions Srandards for Hazardous Air Pollutants. State citations-18 MC 50 Alaska Air Quality Control Regulations; AS 46.03-AS 46.14/18 AAC 52, 18 AAC 53 Alaska Air Statutes.
3. Action-Specific AR4Rs and TBCs page D-3-3 first para.
The text should reference the correct date for “Interim Guidance for Storage, Remediation, and Disposal of Non-UST Petroleum Contaminated Soils” as July 29, 1991. Same comment applies for 3.2.7 page D-3-1O where the date is incorrectly referenced.
Add to this section the following potential action specific ARARs:
1) Solid Waste Disposal Act-42 USC Sections 6901-6987 Resource Conservation Act,
2) Standards Applicable to Transporters of Hazardous Waste-M CFR Part 263. State citation- AS 46.03. These citations establish standards which apply to persons transporting waste within the U.S. and Alaska.
3) Interim Standards of Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities- 40 CFR 265. State citation: AS 46.03. These citations establish minimum Alaskan standards defining the acceptable management of hazardous waste during the period of interim status and until certification of final closure or, post-closure requirements until post-closure responsibilities are fulfilled.
4) Clean Water Act/EPA Administered Permit Programs: The Nation Pollutant Discharge Elimination System (NPDESI-33 USC Sec. 1251-1376, 40 CFR Part 122, 136 and 403. State citation-AS 46.03. AS 44.46 and 46.03 State regulations concerning 33 USC Set 1251 are found at 18 AAC 70. These citations provide requirements for the discharge of pollutants from any point source into waters of the U.S. Guidelines which establish tes procedures for analysis of pollutants. Standards for discharges from POTWs.
5) National Primary and Secondary Ambient Air Quality Standards0 CFR Part 50. State citations: 18 AAC 15 and AS 46.14. The cititions establish standards for ambient air quality to protect public health and welfare.
6) Under 3.1.8 TSCA section include citation 15 USC Set 2601 to 2671.
7) State of Alaska Oil Pollution Control Law-AS 46.@4/18 AAC 75, 75.319, 75.327, 75.337, Alaska’s Oil and Hazardous Substances & Pollution Control Regulations establish requirements for cleanup of oil and residual petroleum product.
8) National Contingency Plan 199040 CFR 300. These regulations sets out the process for investigating and cleaning up contaminated sites.
3.2.3 Alaska Wastewater Disposal Regulations page D-3-9
ADEC disagrees with the wide sweeping overbroad conclusion that all regulations in this section are administrative. There are specific engineering plan requirements contained in 18 AAC 72.600 (c) and (d1. Discharge criteria are contained in 18 AAC 70.
7 3.2.4 Alaska Solid Waste Management regulations page D-3-9
Please add state citation: AS 46.03 to this section.
3.2.7 ADEC Guidance for Storage, Remediation, and Disposal of Non-UST, Petroleum
Contaminated Soils page D-3-10
ADEC disagrees with the comment that 18 AK 75 regulations are “mainly administrative in nature and are therefore not potential ARARs.” While some are administrative, not all of them are or the qualifier “mainly” would not have been used. 18 AK 75.312 has been listed as an ARAR in the past and qualifies as an applicable requirement. As the Court in United States v. Akzo Coatings of America, 946 F.2d 1409 (6th Cir. 19911, noted: “general requirements containing no specific numerical standards can be enforceable ARARs.” ld. at 1442.
See site file for additional information.

Initial ranking. Action code added because it wasn't when the site was originally ranked.

Louis Howard

11/13/1995

Report or Workplan Review - Other

Staff reviewed and commented on the Approach Document RYFS: Operable Unit A Fort Richardson October 1995.
2.1 Nature of Contamination page 2-5
The text refers to BTEX, GRO, and DRO con&tuents deing compared to the Alaska Cleanup Matrix
cleanup scoresheets. The constituents were considered contaminants if they exceed the Level A
cleanup levels, the most conservative criteria. This conflicts with table 5-l Summary of potential RAOs and ARARs which appears to list BTEX, DRO and GRO at 100,2,000, and 1,000 mg/kg
respectively. If category A is to be considered as ARAR, then 10, 100, and 50 mg/kg for BTEX.
DRO and GRO should be properly referenced in the table. If this is not the case, then please explain in the text why a less stringent level is to be considered more appropriate for the sites at OU A.

Louis Howard

4/19/1996

Report or Workplan Review - Other

Staff reviewed and provided comments on the Draft Remedial Investigation Report Plan OU A March 1996, Fort Richardson, Alaska.
3.5 Nature and Extent of Contamination page 3-11
The text states concentrations of petroleum at the site were compared to non-UST matrix level A as a screening criteria A more appropriate category for screening based on the site conditions would be level C if one were to estimate that over 500 cubic yards of contaminated soils were present at the site.
3.5.1 Cesspool Contamination page 3-12
The text states petroleum hydrocarbons were detected from 2 samples that were quantitated as an
unknown fuel. There is no criteria or cleanup level for unknown fuel. Method 8015 was used to
identify fuel types in this investigation and it is unfortunate that GRO, DRO and TPH analyses were not used instead of 80 15. DEC requests the Army identify which specific range of hydrocarbons are represented by “unknown fuel”. Specifically identify if the fuel falls within the alkane range for gasoline: C6-Cl0 boiling point (bp) 60 C- 170 C, diesel: C10 - C25, bp 170 C - 400 C, residual range organics C25-C45 400 C and 550 C.
If this cannot be done using the available information, then the site may be a good candidate for the State-Fort Richardson Two Party agreement (NON-UST) to better identify what fuel constituents are present using specific analyses pending concurrence by all the project managers.
4.5 Nature and Extent of Contamination page 4-12
The text states category A cleanup criteria was used for screening petroleum hydrocarbons detected in the soils. Using the matrix scoring for site conditions a more realistic category would be category C cleanup criteria: 500 mg/kg gasoline range organics, 1000 mg/kg diesel range organics, and 2000 mg/kg residual range organics.
5.5 Nature and Extent of Contamination page 5-9
The text states category A cleanup criteria was used for screening petroleum hydrocarbons detected in the soils. Using the matrix scoring for site conditions a more realistic category would be category C cleanup criteria: 500 mg/kg gasoline range organ&, 1000 mgkg diesel range organics, and 2000 mg/kg residual range organ&. This would screen out all other results except for the one sample from AP-3619 that exceeds the category C cIeanup criteria for DRO and GRO.
DEC requests these sites be discussed as to what remedial action the Army intends to propose in its feasibility study during the next RPM meeting scheduled in May at Fort Richardson.

Louis Howard

11/27/1996

Report or Workplan Review - Other

Staff reviewed and commented on the Working Draft No. 2 Proposed Plan OU MB November 4,1996, Fort Richardson, Alaska.
General comments
DEC requests the Army include the most current cost estimates for the remedial alternatives and
the latest date for the public meeting/open house.
Specific comments
Page 1 2nd para.
The text states the sites included within Operable Unit (OU) A will be addressed through
removal actions under the two party agreement. Please provide more information in the
document on what type of removal actions are being ccrlsidered for sites in OU-A.
Summary of Site Risks OU A page 5
The text states the cleanup efforts for sites in OU-A will be addressed under two party
agreement. If the remedial alternatives for each site with OU-A are known at this time, then list them in the document. A likely place for listing the alternatives would be under “OU-A History and Extent of Contamination” for each site. It is not anticipated by DEC that the Army conduct a rigorous cost analysis and explanation of each alternative be done for OU A as was done for OU-B.
Evaluation of Alternatives and Preferred Alternative page 9
The text states that the three agencies may modify the preferred alternative presented in the
Proposed Plan if there is new information. DEC requests the Army provide information on when
it can expect to send information on the treatability studies at OU-B to DEC for review and
comment. DEC requests a conference call be made with the Army and EPA to discuss the
ramifications of this new information on the selection of the preferred alternative.

Louis Howard

11/30/1996

Site Characterization Report Approved

Final Remedial Investigation for Building 986. To characterize the nature and extent of contamination at POLLDW, 11 soil borings
and five monitoring wells were installed for the RI. Samples were collected from the sludge
in the dry well. Subsurface soil samples were collected from borings, and groundwater
samples were collected from the monitoring wells. In addition, a field survey was conducted to map vegetation type and wetland boundaries in support of the ecological risk assessment.
Results of the RI field investigation indicate that subsurface soil within a 40-foot radius of the dry well is contaminated with GRO and DRO. One subsurface soil sample collected at a depth of 20 feet BGS contained a concentration of chromium significantly above
background concentrations. The subsurface soil contamination is concentrated at depths
between 15 and 20 feet BGS, which is the depth of the bottom of the dry well. Petroleum
contamination in subsurface soil was found to a maximum depth of 60 feet BGS in a boring
adjacent to the dry well. The estimated maximum volume of contaminated subsurface soil at POLLDW is approximately 3,500 cubic yards. No site-related contaminants were detected in any of the groundwater samples collected at POLLDW.

Louis Howard

1/9/1997

CERCLA Proposed Plan

Proposed plan for Operable Unit A/B received.
Operable Unit A: Roosevelt Road Transmitter Site Leachfield, Laboratory Dry Well, & Ruff Road Fire Training Area. The risks presented in the document are conservative because they are based on future residential land use, which is not likely at this site, thereby overestimating risk for site-specific exposure scenarios.
The conclusion of the baseline HHRA for OU-A is that contaminant levels at the OU-A sites do not represent unacceptable risks to human health, based on EPA criteria. However, the levels of petroleum contamination in the soil do exceed the ADEC soil cleanup criteria. The Army, ADEC, & EPA have elected to pursue further cleanup efforts at these sites under the Two-Party Agreement. Under the agreement, the Army & ADEC will clean up contaminated materials at each site in accordance with applicable State of Alaska regulations. While the specific cleanup actions & the time required to remediate the sites have yet to be determined, the Army & State of Alaska will jointly consider all available information before selecting appropriate OU-A site cleanup activities. Decisions regarding OU-A site cleanup will be documented in accordance with stipulations of the Two-Party Agreement. Because the OU-A sites will be addressed through the Two-Party Agreement, they are not discussed further in this Proposed Plan.

Louis Howard

2/7/1997

Report or Workplan Review - Other

Staff reviewed and commented on the Draft Final Proposed Plan Operable Unites A/B January 1997, Fcrt Richardson, Alaska.
General comments
DEC requests the Army include the complete 800 number and latest date for the start and end of the public comment period at the beginning and end of the document.
Page 1
The sidebar text states collection of groundwater samples will be collected over a 20 year period. DEC requests the text be changed to 30 year monitoring period to be consistent with further discussion under the evaluation of alternatives’ present worth costs.
Evaluation of Alternatives and Preferred Alternative: Compliance with AR~Rs page 14
The text states AK State Water Quality Standards would be achieved through natural attenuation under all of the alternatives. This is in direct conflict with the preliminary treat-ability study results presented by the Army which indicated no natural attenuation is occurring at the site. Also, the text on last page of the document states “...natural attenuation will most likely be ineffective in treating groundwater to attain state and federal water quality standards.” DEC requests text be changed from “natural attenuation” to “natural processes”which would make it consistent with references to “natural processes” under the other criteria listed.

Louis Howard

3/13/1997

Update or Other Action

UPD added on 3/13/97, based on Army Risk Data Report dated 11/8/96. Pathways: groundwater is contaminated and flows to northwest. Potential for vertical migration to groundwater. Receptors: Otter Lake has a groundwater well for potable water; groundwater is not migrating to Otter Lake.

Louis Howard

4/2/1997

Report or Workplan Review - Other

Staff reviewed and commented on the Draft ROD Operable Unit A and Poleline Road Disposal Area-Operable Unit B, Fort Richardson, Alaska dated January 17,1997.
Description of the Selected Remedies page ii
In the section where institutional controls are first mentioned, please define the terms: SDWA and MCLs for the reader.
Statutory Determination page ii
In this section it may be appropriate to mention a phased approach for the selected remedy & alternate treatment technologies. Other points to mention in this section are how & why the selected remedy will be phased and what triggers or sets forth in motion when the Army will consider looking at another treatment technology.
Signatures page v
DEC suggests a language change in this section for the State to read as follows: This signature sheet documents agreement between the U.S. Army and the United States Environmental Protection Agency on the Record of Decision for Operable Unit B at Fort Richardson.” The Alaska Department of Environmental Conservation concurs with the Record of Decision.” Please list Kurt Fredriksson as signatory for ADEC in this section.
1.1.2 Hydrogeology and Groundwater Use pages 2 and 3
This section is too vague and does not give the reader the impression that it applies specifically to OU A source areas. The description needs to mirror or be more like section 1.2.2 for OU B or incorporate information from previous investigations concerning hydrogeology and groundwater usage.
2.3 Highlights of commuuity Participation pages 13 and 14
DEC requests the Army include in this section a reference to the newsletters that discussed the timelines for work at OUs A and B. Other items which the Army has used in the past to inform and solicit public input regarding environmental programs include: solicitations for starting a Restoration Advisory Board, public informational meetings, newspaper. releases, public notices. These may also be listed in this section.
3.1.2.1 Roosevelt Road Transmitter Site Lea&field page 17 first, third and fourth para.
Text in first paragraph & third paragraph needs to relate analytical results to Alaska cleanup matrix (ACM) levels, EPA’s Region III RBCs & possibly TSCA (for soil samples that contain PCBs). DEC requests changes to language in fourth paragraph on this page from "...concentrations exceeding screening criteria. . . .” to “the concentrations exceeding MCLS in the . . . groundwater samples.”
3.1.2.2 Ruff Road Fire Training Area page 18 first para.
Please change the text in last sentence referencing figures 34 and 3-5 to tables 3-4 and 3-5.
3.1.2.3 Petroleum Oil and Lubricant Laboratory Dry Well page 18 fifth para.
The text should state the petroleum constituents detected exceed ACM levels & the other contaminants detected (where applicable) do not exceed EPA’s Region III RBCs.
4.1.1.1 Soil page 54 second para.
The text states that for the cesspool area the potential future RME industrial and residential exposures to soil were calculated to be 1 x l0-5 and 5 x 10-5 respectively. However, Table 4-l “Human Health Risks” only specifies residential exposure scenarios of 2 in 10 million for the leachfield with no reference to industrial exposure or what media type is driving the risk. Please clarify and address this discrepancy. It appears that the Laboratory Dry Well source area did not have any text regarding the analysis of risk in this particular section, however human health risks were presented for the Dry Well in Table 4-l. Please add language to this section listing excess lifetime risks for potential future RME exposures for this source area.
Table 3-l through 3-8
DEC requests revising the tables to list all organic and inorganic COPCs which were analyzed for into one table for each media type and each source area within OU A. After listing the compounds that were analyzed, list in another table for each source area only those compounds which exceed a specific criterion. For example: identified COPCs would include samples that exceed ACM criteria or MCLs, EPA’s Region III RBCs, or have a hazard index > 1.
DEC suggests formatting for tables listing compounds of potential concern include headings:
analyte, frequency of detection, maximum detected result, location of maximum concentration (for soils: include depth bgs), cleanup guideline (ACM, MCLs, RBCs, or His). The listing of RBCs based on l0-6 risk would replace l0-7 screening concentrations. Please elaborate further in the footnote section for Ruff Road Fire Training Area table 3-5 page 38 the definition of “TEF’ or include it in the glossary and define it in laymen’s terms where it is first used in the document.
Tables 4-1 and 4-2 pages 67 and 68
DEC suggests these two tables be combined into one table summarizing: soil risk for each site (carcinogenic vs. noncarcinogenic) and their respective residential and recreationaI scenarios, and the chemicals driving risk (a.k.a. COCs).

Louis Howard

9/18/1997

Record of Decision

Petroleum contamination in the soils surrounding the dry well will be excavated during the field season of 1998. Sludge in the dry well was not evaluated directly in the Risk Assessment because of the lack of exposure pathways, it is contaminated and could present a health risk if contacted by humans. Sludge in the dry well will be disposed of during the removal of the POL contaminated soils under the State Fort Richardson Environmental Restoration Agreement to which this site was transferred back to under the ROD. Removal actions occurred during the summer of 1998.

Quarterly update received stating that system operations continue for the vapor extraction system at 986.

Louis Howard

7/27/1999

Update or Other Action

Vapor extraction report received. Report stated removal of petroleum contaminants continue at a reduced rate. It suggests that the Army may want to consider converting the system over to bioventing instead of vapor extraction.

Louis Howard

10/29/1999

Update or Other Action

Quarterly update received. Soil vapor extraction system converted over to bioventing system to be operated for a period of one year. SVE system was augmented and 14 bioventing wells were installed around the perimeter of the site.

Louis Howard

1/3/2001

Report or Workplan Review - Other

Staff provided comments on the letter reports for Building 986 POL laboratory. Staff requested more timely submittals from the Army if it desired substantive comments from ADEC. Reports date back to April 2000. Staff requested sampling or BTEX in addition to GRO, DRO and RRO.

Louis Howard

2/22/2001

Report or Workplan Review - Other

EPA comment letter sent for RCRA closure under the 1991 Fort Richardson FFCA. FFCA required USARAK submit closure/post closure plans for this unit. No record is a available of closure plans being submitted. OUA ROD stated that a removal action was conducted in 1992 and confirmatory samples were taken of the area around the tank.
The documentation in the CERCLA administrative record did not include the results of confirmatory sampling for this unit. USARAK must provide to EPA the documentation that the removal took place, including the results of the confirmatory sampling that show the area meets the cleanup standards at 18 AAC 75 before EPA can consider this unit clean closed.

Louis Howard

11/21/2001

Update or Other Action

Staff reviewed and commented on the draft sampling and analysis workplan for Building 986. Staff Approved plan as submitted.

Louis Howard

12/12/2001

Update or Other Action

1. All organizations conducting activities on United States Army Alaska (USARAK) controlled land are responsible for complying with established institutional controls (ICs). ICs are administrative, procedural, and regulatory measures to control human access to and usage of property. They are applicable to all known or suspected contaminated sites where contamination has been left in place.
2. These controls have been established to implement the selected remedial actions agreed upon by the U.S. Army (Army), the U.S. Environmental Protection Agency (USEPA), and the Alaska Department of Environmental Conservation (ADEC) in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as amended by the Superfund Amendment Reauthorization Act (SARA). These controls also apply to remedial actions agreed upon under Two-Party Compliance Agreements. These agreements are concluded between USARAK and ADEC and apply to petroleum/oil/lubricants- (POL) contaminated sites.
3. ICs such as limitations on access, water use, excavations, and property transfers will supplement engineering controls as appropriate for short-term and long-term management to prevent or limit human and environmental exposure to hazardous substances, pollutants, or contaminants. Specific ICs include, among other things: limitations on the depth and location of excavations, prohibition of or restrictions on well drilling and use of ground water, requirements for worker use of personal protective equipment, site monitoring, and prohibition of certain land uses, types of vehicles, etc.
4. Organizational units, tenants, and support/contractor organizations must obtain an Excavation Clearance Request (ECR) for all soil disturbing activities impacting soils six inches or more below the ground surface. The review process for approval of an ECR begins with the identification of the current status (known or suspected hazardous waste site or “clean” site) of a work location. ECR’s for work in known or suspected hazardous waste sites:
a. will include specific limitations and controls on such work;
b. will include specific IC procedures, and notification, monitoring, reporting, and stop work requirements;
c. may include procedures for management, characterization, and disposal of any soil or groundwater encountered or removed;
d. will identify “project managers” for both the unit/contractor requesting the work and DPW Environment Resources.
5. The DPW project manager will conduct on-site inspections of each work site (at which ICs apply) to determine continued compliance with the terms and conditions of the approved ECR. DPW has the authority to revoke ECR approval if the specified terms and conditions are not being met. ECR forms are available at the Customer Service Desks at: a. Building 730 at Fort Richardson; b. Building 3015 at Fort Wainwright; c. Building 605 at Fort Greely.
6. USARAK has negotiated (with USEPA and/or ADEC) decision documents and/or Records of Decision (RODs) that mandate the implementation of ICs USARAK Directorate of Public Works, Environmental Resources Department (PWE), maintains copies of all decision documents and RODs requiring ICs in its real property files. PWE provides regularly updated post maps showing all areas affected by ICs. These maps can easily be accessed by using an approved intranet mapping interface application. Copies of these maps will be available to each directorate, activity, and tenant organization. To ensure the effectiveness of ICs, all organizational units and tenant activities will be informed on an annual basis of ICs on contaminated soils and groundwater in effect near their facilities.
7. ICs are enforceable by the U.S. Environmental Protection Agency (USEPA) and the Alaska Department of Environmental Conservation (ADEC). Failure to comply with an IC mandated in a decision document or ROD will violate the USARAK Federal Facility Agreement and may result in stipulated fines and penalties. This does not include the costs of corrective actions required due to violation of an established IC.

Louis Howard

4/16/2002

Report or Workplan Review - Other

Staff reviewed and commented on the Draft Quarterly Respirometer Test 1 of 5 for Building 986 POL Lab Fort Richardson, Alaska dated March 2002 Contract Number DACA85-01-P-0080 Project #200110. Staff concurred with the conclusion that the system is currently working as designed to remediate the soils at the site.

Louis Howard

7/1/2002

Report or Workplan Review - Other

Staff reviewed the draft quarterly respirometer test 2 of 5 for the site. Staff concurred with the conclusion that the system is currently working as designed to remediate the soils.

Louis Howard

2/20/2003

CERCLA ROD Periodic Review

Jennifer Roberts (ADEC) signed the five-year review document. Some general recommendations were given in the document.
The Army has established Standard Operating Procedures (SOP) and a Geographic Information System (GIS) based tracking system to ensure the land and use restrictions are enforced. The IC system has been incorporated into the post wide Master Plan, and compliance with ICs is reported in the Annual Monitoring Reports for each OU. The IC policy applies to all USARAK units and activities, Military and Civilian Support Activities, Tenants Organizations and Agencies and Government and Civilian Contractors. In the fall of 2001, the Institutional Control Memorandum signed by Major General Cash dated February 1999, was updated to require a Work Authorization Permit for all groundwater and soils on USARAK lands. This revised memorandum, signed by the Commanding General, includes a section on areas with ICs mandated by a Record of Decision and a section on areas where contamination is not suspected. Currently, all contracts that include intrusive activities require a Work Authorization Permit; however, the Permit was updated to clearly alert the user on procedures to follow when potential contamination is encountered. The Standard Operating Procedure (SOP) for ICs will include a more detailed section on the procedures and responsibilities for incidents where potential contamination is found.
Fort Richardson instituted a post wide IC policy for all known or suspected contaminated source areas. Further details of the Army/Fort Richardson IC policy can be found in Appendix E of the OUB Draft Interim Remedial Action Report, the U.S. Army Alaska Institutional Controls Standard Operating Procedures [(APVR-RPW [200-1)], and a Memorandum on Institutional Controls [APVR-RPW-EV (200-1c)]. USARAK DPW maintains the GIS database with information on all of the contaminated source areas on Post. The DPW is responsible for ensuring compliance with ICs on Fort Richardson. ICs will remain in place as long as hazardous substances remain on site at levels that preclude unrestricted use.
Institutional Controls do not specifically address UXO hazards at OUB; therefore identifying UXO specific ICs is recommended to prevent and limit human and environmental exposure to hazardous substances.
The EPA has been working with federal agencies for several years to address perchlorate as an environmental contaminant. Ammonium perchlorate is a component of solid rocket fuel and is believed to be a widespread environmental contaminant. Based on the EPA’s “Interim Assessment Guidance for Perchlorate”, the Army initiated a program in 2002 to identify sites where solid rocket fuel had been stored or disposed, and to determine whether or not groundwater sampling had been conducted at these sites. Based on the results of the perchlorate survey, the Army will investigate potential sites further, and potentially collect and analyze groundwater for the presence of perchlorate.
The next Fort Richardson Five-Review will be conducted in 2008, five years from the date of this review. The next Five-Year Review will be the first full-term review for the OUC ROD.

Jennifer Roberts

12/31/2003

Update or Other Action

SVE/Bioventing system was shut down.

Louis Howard

4/2/2004

Report or Workplan Review - Other

Staff reviewed and commented on the draft remedial action report for the site. Staff requested that the Army outline what steps it plans to take regarding the residual contamination left in place at the site.

Louis Howard

5/19/2004

Institutional Control Record Established

Land use controls required at the site since contamination is in place which would not allow for unrestricted use.

Louis Howard

5/19/2004

Conditional Closure Approved

Based on ADEC's review of the document and soil/groundwater data collected to date, the Department finds the residual contamination at Building 986, does not pose a significant threat to human health or safety, or the environment and therefore, no further remedial action or soil sampling is required for this site. Since contaminated soil remains at the site, institutional controls will be required identifying the site as having soil contaminated above those which would allow for unrestricted use (e.g. level “A” criteria).
In the event the contaminated soil is uncovered during the removal of Building 986 or becomes accessible by excavation at the site, the Army will be required under 18 AAC 75.300 to notify the Department and properly transport and dispose of the soil with prior approval in accordance with 18 AAC 75.325(i). The Department reserves all of its rights, under A.S. 46.03, 18 AAC 78, and 18 AAC 75 to require the Army to conduct additional site assessment, remediation, and/or other necessary actions if information becomes available that contamination is found which poses a risk to human health or safety, welfare, or the environment.
The following policy applies for soil regulated under 18 AAC 75 and 18 AAC 78 that is proposed for disposal off site from where it was generated. If the following criteria is met, ADEC approval and/or an institutional control(s) are not required:
1. The soil meets the most stringent Method Two, Migration to Groundwater, Table B2 cleanup level, and the most stringent standards for those chemicals under Table B1;
2. The soil may only be disposed of at any non-environmentally sensitive location in the Under 40" or Over 40" annual precipitation zone;
3. The soil is not placed within 100 feet of water wells, surface waters, and drainage ditches; and
4.The written approval from the landowner of the off-site location is required.
The off site disposal of all other soil subject to the site cleanup rules that does not meet the criteria above shall be reviewed by the ADEC project manager in order to determine if the off-site disposal action poses a current or future risk to human health or the environment. The final approval to dispose of soil off site that does not meet the criteria shall be made by the ADEC Section Manager.
Terms used in this document have the meaning given in 18 AAC 75.990 including: “environmentally sensitive area” means a geographic area that, in the department's determination, is especially sensitive to change or alteration, including:
(A) an area of unique, scarce, fragile, or vulnerable natural habitat;
(B) an area of high natural productivity or essential habitat for living organisms;
(C) an area of unique geologic or topographic significance that is susceptible to a discharge;
(D) an area needed to protect, maintain, or replenish land or resources, including floodplains, aquifer recharge areas, beaches, and offshore sand deposits;
(E) a state or federal critical habitat, refuge, park, wilderness area, or other designated park, refuge, or preserve; and
(F) an area that merits special attention as defined at 6 AAC 80.170 (Repealed see AS 46.40.210(1))
“area which merits special attention” means a delineated geographic area within the coastal area which is sensitive to change or alteration and which, because of plans or commitments or because a claim on the resources within the area delineated would preclude subsequent use of the resources to a conflicting or incompatible use, warrants special management attention, or which, because of its value to the general public, should be identified for current or future planning, protection, or acquisition; these areas, subject to council definition of criteria for their identification, include:
(A) areas of unique, scarce, fragile or vulnerable natural habitat, cultural value, historical significance, or scenic importance;
(B) areas of high natural productivity or essential habitat for living resources;
(C) areas of substantial recreational value or opportunity;
(D) areas where development of facilities is dependent upon the utilization of, or access to, coastal water;
(E) areas of unique geologic or topographic significance which are susceptible to industrial or commercial development;
(F) areas of significant hazard due to storms, slides, floods, erosion, or settlement; and
(G) areas needed to protect, maintain, or replenish coastal land or resources, including coastal flood plains, aquifer recharge areas, beaches, and offshore sand deposits.

Louis Howard

5/27/2005

Update or Other Action

Report listed Section, Township, Range for site.

Louis Howard

11/1/2005

Update or Other Action

As a result of the 2005 BRAC, Fort Richardson and Elmendorf AFB were realigned and created JBER as of October 1, 2010. “BRAC" is an acronym which stands for base realignment and closure. It is the process DoD has previously used to reorganize its installation infrastructure to more efficiently and effectively support its forces, increase operational readiness and facilitate new ways of doing business. DoD anticipates that BRAC 2005 will build upon processes used in previous BRAC efforts.
The Base Realignment and Closure (BRAC) Commission in 2005 recommended the transfer of installation support functions of Ft Richardson to Elmendorf AFB establishing Joint Base
Elmendorf-Richardson. The recommendation became law in November 2005.
Realignment
Includes any action that both reduces and relocates functions and civilian personnel positions, but does not include a reduction in force resulting from workload adjustments, reduced personnel or funding levels, or skill imbalances.
Fort Richardson and Elmendorf Air Force Base were realigned to form Joint Base Elmendorf-Richardson (JBER) which will became fully operational on 1 October 2010. Joint Base Elmendorf-Richardson met the milestone of Full Operational Capability, Friday, as mandated by the 2005 Base Realignment and Closure law.
FOC means JBER has merged installation management functions and assets to become the sole provider of support, services and a home to more than 40,000 Airmen, Soldiers, family members, retirees and civilians.
Joint Base Elmendorf-Richardson will be commanded by an Air Force colonel with an Army colonel as a deputy. As for the commanders of the Service specific missions (e.g. 3rd Wing and U.S. Army
Alaska, as well as other supported units), the current commanders will remain in charge of their units until they are replaced by follow-on mission unit commanders.

DP009 – Building 986 Dry Well SC WP received.
DP009-SB01 & DP009-SB02
Two borings will be drilled near the former dry well to investigate the area of residual contamination. The proposed new borings are located where the vadose zone is interpreted to still be contaminated.
Soil borings will be advanced to approximately 40' bgs. Soil cores will be examined for evidence of hydrocarbons (e.g., staining or odor) & will be screened for organic vapors using a PID meter. If evidence of contamination is identified within the soil collected at 40' bgs, then at least two additional samples (for a total of 10 additional vertical ft) will be collected. Lithologic descriptions, observations of staining or odor, & the results of field screening with the PID will be recorded on borehole log forms.
Based on field observations & the results of the PID screening, soil samples within each 5-foot interval will be selected for laboratory analyses (up to 16 primary samples). All soil samples will be analyzed for GRO, DRO, RRO, VOCs (petroleum-related compounds).
To facilitate HRC calculations, a subset of soil samples will be collected & analyzed as follows:
- Approximately two soil samples (excluding QC) from more heavily contaminated soils (as observed at the time of sampling based on PID readings & visual/olfactory evidence of contamination) will be analyzed for PAHs, VPH, & EPH.
- Approximately one soil sample from uncontaminated soils that are representative of the source zone will be analyzed for foc.
- Approximately one soil sample representative of the site subsurface conditions, will be analyzed for bulk density, grain size distribution, specific gravity, & moisture content.
If monitoring well AP-3648 exists, is able to be sampled, & contains sufficient water for purging, samples will be collected from the top of the water table & analyzed for VOCs (petroleum-related compounds), GRO, DRO, RRO, PAHs, VPH, & EPH. Observations of odor, turbidity, & color will be recorded on the GW sample collection log.
GW is not anticipated to be encountered during this investigation in either boring. However, if a perched aquifer is encountered with enough GW to be sampled, samples will be collected from the top of the water table & analyzed for petroleum-related VOCs, GRO, DRO, RRO, PAHs, VPH, & EPH. Observations of odor, turbidity, & color will be recorded on the GW sample collection log.
If, for petroleum hydrocarbons, potential risk is indicated by the HRC or if vadose zone soils exceed MAC, then remedial options that address the contaminants of concern & associated exposure routes that contribute enough risk to cause the cumulative risk estimate to exceed the risk standard will be evaluated. If excavation is the selected alternative, the contaminated soil will be excavated up to a depth of 25' bgs, where possible.
The following decision rules will be used to determine whether excavation is necessary:
• DRO soil contamination in the upper 15' bgs with concentrations greater than approximately 10,250 mg/kg will be the target of excavation.
• Soil contamination creating unacceptable vapor intrusion or migration-to-GW risk up to 25 feet bgs will be excavated if soil contamination below 25' bgs does not create unacceptable risk.
If excavation is selected as the remedial approach, field screening & soil sampling will be performed in accordance with ADEC Field Sampling Guidance (2010). During excavation, the PID will be used to screen soil using a level of 20 ppm to separate “dirty” soil from “clean” soil at a rate of one field screening sample per every 10 cy of soil.
SOP-05 provides the methodologies to be followed for field screening. The “dirty” & “clean” soil will be placed into separate stockpiles. Discrete soil samples will be collected from stockpiles & submitted for laboratory analysis of GRO, DRO, RRO, petroleum-related VOCs, & PAHs at a rate of two for the first 50 cy of stockpiled soil with an additional sample for each additional 50 cy.
After field screening, confirmation samples from the floor and sidewalls of each excavation will be collected from field-screening locations with the highest PID readings for laboratory analysis of GRO, DRO, RRO, petroleum-related VOCs, and PAHs. Soil sampling procedures are outlined in SOP-16.
For sidewalls, one soil confirmation sample will be collected per every 20 linear ft of excavation. For the excavation base, 2 samples will be collected for the first 250 sq ft and one for each additional 250 sq ft. Absence of positive field screening results or those field screening results below the 20 ppm threshold will not be used alone as justification for not taking the associated number of laboratory analytical samples.

Louis Howard

3/4/2013

Report or Workplan Review - Other

Staff provided review comments for the draft UFP-QAPP.
General Comments for JBER-E and JBER-R sites
ADEC requests JBER provide the following location information for each site will be provided for in the Executive Summary text:
Please provide latitude and longitude coordinates for the site location in decimal degree format with a precision of six decimal places (dd.dddddd). Also include the following:
1. Date of collection,
2. Method of collection (i.e. GPS, hardcopy map, air photo),
3. Scale of the map used to acquire coordinates (if applicable),
4. Estimated accuracy and associated unit of measure,
5.Reference point for which the coordinates were established (i.e. center of property, entrance gate),
6.Horizontal datum (NAD 1983 is strongly preferred) and
7. Comments for additional information regarding acquistion of coordinates (if necessary).
Executive Summary
Site-Specific Background
Add text for the following report:
Soil Quality Assessment Building 986 October 1990 (Shannon & Wilson for Brown & Root Services Corporation) per Work release number R00309/432 signed on August 31, 1990.
In 1990, two soil borings were advanced to evaluate whether the activities associated with the existing UST and the dry well have had an impact on the soil at the proposed new UST location. Borings TB-1 and TB-2, were each drilled to a depth of 21.5 feet. Boring TB-1 was positioned midway between the existing underground storage tank (UST) and the proposed UST site. Boring T3-2 was placed adjacent to the proposed UST location.
Page ES-3
Site-Specific Proposed Work
2nd Bullet
ADEC will require JBER to report all VOCs from method 8260c not just BTEX fuel related analytes.
Page ES-4
The text states one sample will be collected from below the contaminated soil source and analyzed for fraction organic carbon (foc). See comment #9 below.
Last bullet
ADEC will require EDB be included with the list of other analytes for groundwater due to sources such as motor gas, aviation fuel that would contain EDB. If EDB is detected in the groundwater above Table C cleanup levels, then JBER shall sample the soil for EDB and include lead in future groundwater sampling events.
EPA 8011 or EPA 504.1 should be used when evaluating ethylene dibromide (EDB). EDB soil samples should be field preserved in hexane. EPA 8260 will quantify EDB in ground water; however, the detection limits do not meet the Table C cleanup level of 0.00005 mg/L (ADEC Draft Field Sampling Guidance May 2010).

Louis Howard

5/6/2013

Report or Workplan Review - Other

ADEC has received the final version of the UFP-QAPP SC Work Plan for DP009 Bldg. 986 ADEC CS DB Hazard ID 943 on JBER-Richardson on April 18, 2013. ADEC has reviewed the document and has no further comments on it. The document is approved

Louis Howard

6/11/2013

Exposure Tracking Model Ranking

Initial ranking with ETM completed for source area id: 71922 name: Dry Well

Louis Howard

3/6/2014

Update or Other Action

Draft Site Characterization report received for review.
The highest detected concentrations of DRO were 315 mg/kg (boring DP009-SB01, from 15 to 20 feet bgs) and 413 mg/kg (boring DP009-SB02, from 15 to 20 feet bgs). The GRO concentration was above screening levels in one sample from location DP009-SB01 at 339 mg/kg (from 15 to 20 feet bgs).
Three VOCs were detected above the respective screening levels: benzene (0.025 mg/kg), tetrachloroethene (PCE) (0.024 mg/kg), and trichloroethene (TCE) (0.02 mg/kg). The highest concentrations of the VOCs that exceeded screening levels are summarized below:
• Benzene at DP009-SB01: 20 to 25 feet bgs, 0.46 mg/kg
• PCE at DP009-SB02: 15 to 20 feet bgs, 0.0397 mg/kg
• TCE at DP009-SB02: 20 to 25 feet bgs, 0.028 mg/kg
Nineteen VOCs were detected in soil below the respective screening levels (Table 4-1). VOC results that were flagged (J) indicate that the analyte was positively identified, but the
quantitation is an estimation.
Risks posed by the GRO, DRO, and RRO aromatic and aliphatic fractions are below the regulatory risk standard of 1 for each pathway with two exceptions. GRO aromatics and aliphatics exceed the risk standard of 1 for indoor air inhalation under the residential scenario.
• PCE and TCE are not believed to have been analyzed for in the past at DP009; however,
benzene had previously been detected throughout the source area and was treated via the
former SVE/biovent system. Based on the results of the 2013 sampling, benzene remains in soil above project screening levels and extends vertically to 30 feet bgs. The lateral extent of
TCE, PCE, and benzene in soils has not been defined and represents a data gap.
• No contaminants were detected in existing groundwater monitoring well AP-3648 at concentrations above project screening levels, and groundwater was not encountered during soil boring activities at locations DP009-SB01 and DP009-SB02.
• For the DRO/GRO source area, the carcinogenic cumulative risk does not meet the regulatory limit of 1E-05 for current industrial (2E-05) or future residential (6E-05) scenarios. The noncarcinogenic cumulative risk meets the regulatory limit of 1 for current industrial (0.1) and future residential (0.6) scenarios. The primary contributors to carcinogenic risk for the industrial scenario are benzene and PCE in indoor air; the primary contributor to carcinogenic risk for the residential scenario is benzene in indoor air.
• For the VOC-only source area, the carcinogenic cumulative risk meets the regulatory limit of
1E-05 for current industrial (2E-06) and future residential (1E-06) scenarios for the direct
contact, outdoor inhalation, and groundwater ingestion pathways. The noncarcinogenic
cumulative risk meets the regulatory limit of 1 for current industrial (0.02) and future
residential (0.03) scenarios for contaminants outside the soil source area. For the vapor
intrusion pathway, benzene and TCE concentrations exceed 18 AAC 75.345 Table B1 cleanup levels, indicating that further evaluation is necessary to assess possible vapor intrusion risk.
The following are recommended for DP009:
• Investigation of the vapor intrusion pathway in two phases, as follows, before decisions
about potential remedial actions are made. A separate work plan would be developed for the
recommended work.
• Phase I – soil gas screening to guide placement of TO-15 soil gas samples:
Perform a soil gas screening evaluation in the area between the source area and Building
986 to better define the extent of VOCs in soil and to guide placement of TO-15 soil gas
samples collected in Phase II.
Conduct screening in a grid-type pattern via temporary vapor probes installed to approximately 5 feet bgs. Soil gas samples from the temporary probes would be screened with a portable gas chromatograph (GC) with a photoionization detector (PID) (FROG-4000™ by Defiant Technologies, Inc.).
• Phase II – soil gas sampling to determine whether further action is necessary and estimate a
soil target area, if necessary.
Sample up to three of the temporary soil gas probes installed in Phase I and analyze by
Method TO-15 or TO-17 for petroleum-related VOCs (as listed in Appendix E of the
ADEC Vapor Intrusion Guidance [ADEC, 2012b]), TCE, and PCE. Soil gas sampling
would be conducted in accordance with the Soil Gas Sampling Plan Addendum to the
Basewide QAPP (WESTON, 2013b).
Compare soil gas concentrations to ADEC shallow soil gas target concentrations
(ADEC, 2012b) to determine whether further action is necessary to achieve “Cleanup
Complete without ICs” or UU/UE and estimate a soil target area, if necessary.
• No further investigation or cleanup of DRO and GRO in soil or groundwater.

Louis Howard

4/3/2014

Report or Workplan Review - Other

Staff provided comments on the draft SC report.
Site Overview
The text states: “As a result, ADEC approved closure of the site with ICs in 2004.”
ADEC requests the text state: “As a result, ADEC approved closure of the site with ICs in 2004 and the site is assigned a “Cleanup Complete with Institutional Controls” status.
Summary of 2013 Site Characterization Activities
The text states: “Fifteen primary soil samples were collected and submitted
to Applied Sciences Laboratory (ASL) for analysis of GRO, DRO, residual-range organics (RRO), volatile organic compounds (VOCs) (including low level-VOCs), extractable petroleum hydrocarbon (EPH), volatile petroleum hydrocarbon (VPH), and polycyclic aromatic hydrocarbons (PAHs).”
Please state here and elsewhere as applicable that Applied Sciences Laboratory (ASL) is the CH2M Hill-Corvalis laboratory, UST-079.
Nature and Extent
The text states: “DRO, GRO, benzene, trichloroethene (TCE), and tetrachloroethene (PCE) are the primary COPCs at the site.
Please state: “DRO, GRO, benzene, trichloroethene (TCE), and tetrachloroethene (PCE) are the primary COPCs at the site. It should be noted that TCE and PCE were not detected prior to the 2013 site characterization.”
The text states: “VOCs including benzene, PCE, and TCE are also present in the area of the former dry well, and were detected above the respective screening levels in soil borings DP009-SB01 and DP009-SB02. PCE and TCE are not believed to have been analyzed for in the past at DP009.”
ADEC requests text be added to state how close the Tetrachloroethylene (PCE) and Trichloroethylene (TCE) contamination are to existing buildings. The conceptual site model (CSM) may need to be refined for vapor intrusion concerning PCE and TCE. The ADEC CSM Guidance (October 2010) contains a list of volatile compounds and discusses when a building is close enough to contamination to prompt additional evaluation (less than 30 feet from a petroleum source or less than 100 feet from a non-petroleum source). Once determined to be complete, the vapor intrusion pathway must be evaluated further as described in the ADEC Vapor Intrusion Guidance for Contaminated Sites (October 2012).
Buildings within 100 feet laterally of subsurface vapor sources (or 100 feet vertically of underlying vapor sources) should be considered “near” for purposes of a preliminary analysis, under the assumption that preferential vapor migration pathways are absent. When present, they may facilitate subsurface vapor migration over distances greater than 100 feet . (EPA VI Final Guidance for Assessing and Mitigating the Vapor Intrusion Pathway From Subsurface Sources to Indoor Air (April 2013). Any vapor intrusion investigation is in addition to the required nature and extent investigation required by 18 AAC 75.335 (a) Site Characterization.
Nature and Extent
1st Paragraph
The text states: “Although residual DRO and GRO concentrations are above project screening levels, the source area has been sufficiently delineated laterally and vertically for the purposes of evaluating current and future site risk related to petroleum.”
ADEC requests text be added to discuss the lateral and vertical extent of TCE and PCE above screening levels and whether it has been sufficiently delineated.
3rd Paragraph
The text states: “Based on the results of the 2013 sampling, benzene remains in soil above project screening levels and extends vertically to 30 feet bgs.”
ADEC requests clarifying text regarding TCE and PCE contamination and whether it too was detected vertically to 30 feet bgs or if it still needs to be investigated.

Louis Howard

4/9/2014

Report or Workplan Review - Other

ADEC RTCs for Soil Gas Sampling Work Plan Addendum ADEC specific comments
Issue: introduction text did not incorporate any of the recommended changes in the RTC to the SOP-5c (section 1.0? or elsewhere).
Comment #1 WESTON has added text to the soil gas SOP INTRODUCTION to address the comment. The text insert (on page 3) says “If the site-specific criteria in the June 28, 2013 ADEC-USAF-Weston meeting minutes are met, indicating vapor intrusion potential, and the site has non-hydrocarbon contaminants which do not biodegrade under aerobic conditions (for example a waste oil site with chlorinated compounds), then soil gas samples will be collected regardless of the soil oxygen concentration.”
We also think that the June 28, 2013 ADEC-USAF-Weston meeting minutes addresses this issue, as follows:
3.2 The VI pathway will be considered potentially complete if non-hydrocarbon VOC contamination above 18 AAC 75 Table B1 and C levels is present within 100 feet (vertically or horizontally) of the foundation of a currently occupied or occupiable building.
3.3 If the VI pathway is potentially complete, soil gas samples will be collected and analyzed by TO15. The TO15 analyte list with non-hydrocarbon contaminants includes the full list in Appendix E in the ADEC VI Guidance. The resulting contaminant concentrations in soil gas will be compared to screening levels listed in the ADEC VI guidance and/or used as input to the Hydrocarbon Risk Calculator (HRC).
Comment #2WESTON has added text to the soil gas SOP INTRODUCTION to address the comment (page 4). The text insert says “In general, TO-15 analysis run on 1 liter SUMMATM canisters will be the default laboratory method…..”.
Note that the table embedded in the text of the soil gas SOP which describes the analytical methods indicates that the TO-15 analysis will use 1 liter SUMMATM canisters as the collection device, and that the TO-17 analysis will use sorbent tubes as the collection device.
All other RTCs are acceptable to ADEC with the exception of the introduction text additions for comment 1 and 2 that did not make it to the SOP.....

Louis Howard

5/16/2014

Report or Workplan Review - Other

Staff provided comments on the JBER Draft DP009 Additional Site Characterization Work Plan Addendum-ADEC comment
JBER text: “Quality control (QC) samples will include one field duplicate (FD) (collected at a frequency of 10 percent as outlined in Worksheet #20 of the Site Characterization Work Plan). Table 1 presents a summary of samples, analysis, and rationale for collection.”
JBER Work Plan WS#20 Field QC Summary: “Field QC summary follows the JBER Basewide UFP-QAPP and includes collecting duplicates and MS/MSDs at a rate of 10 and 5 percent, respectively (USAF, 2013). The anticipated number of duplicates and MS/MSD samples are presented in Table 20-1 (a lower number of duplicates and MS/MSD samples may be collected if the DP009 samples are collected as part of a program and submitted for laboratory analysis with samples from other sites).”
ADEC: Comment
1) ADEC will REQUIRE that all QC samples (e.g. duplicates, MS/MSD, etc) be collected as required by the UST Procedure Manual Table 4 on a SITE-SPECIFIC basis (no pooling of QC samples as part of a “program” or larger “JBER Project”).Table 4 shows the minimum level of sample QC scrutiny that must be applied to field sampling. A description of each type of field QC sample appears in Sections 9.1.2. - 9.1.5 of this chapter.
Reference to sets of samples in this and subsequent subsections refers to samples taken from the same site (or, for multiple sampling points within a single project, from the same area within a site that has uniform characteristics such as grain size and organic content) during the same sampling event during a discrete time period. It does NOT apply to sampling points from DIFFERENT sites, samples taken at significant time differences from each other, nor multiple samples from the same site, but with non-uniform site characteristics. A lower number of duplicates and MS/MSD samples will not be acceptable to ADEC on this or SS019 or any other site, regardless if collected part of a program or JBER Project.

Louis Howard

5/22/2014

Update or Other Action

JBER text: “Quality control (QC) samples will include one field duplicate (FD) (collected at a frequency of 10 percent as outlined in Worksheet #20 of the Site Characterization Work Plan). Table 1 presents a summary of samples, analysis, and rationale for collection.”
JBER Work Plan WS#20 Field QC Summary: “Field QC summary follows the JBER Basewide UFP-QAPP and includes collecting duplicates and MS/MSDs at a rate of 10 and 5 percent, respectively (USAF, 2013). The anticipated number of duplicates and MS/MSD samples are presented in Table 20-1 (a lower number of duplicates and MS/MSD samples may be collected if the DP009 samples are collected as part of a program and submitted for laboratory analysis with samples from other sites).”
ADEC: Comment
1) ADEC will REQUIRE that all QC samples (e.g. duplicates, MS/MSD, etc) be collected as required by the UST Procedure Manual Table 4 on a SITE-SPECIFIC basis (no pooling of QC samples as part of a “program” or larger “JBER Project”).Table 4 shows the minimum level of sample QC scrutiny that must be applied to field sampling. A description of each type of field QC sample appears in Sections 9.1.2. - 9.1.5 of this chapter.
Reference to sets of samples in this and subsequent subsections refers to samples taken from the same site (or, for multiple sampling points within a single project, from the same area within a site that has uniform characteristics such as grain size and organic content) during the same sampling event during a discrete time period. It does NOT apply to sampling points from DIFFERENT sites, samples taken at significant time differences from each other, nor multiple samples from the same site, but with non-uniform site characteristics. A lower number of duplicates and MS/MSD samples will not be acceptable to ADEC on this or SS019 or any other site, regardless if collected part of a program or JBER Project.
JBER Response:
1. As described in the text and shown in Table 1, three primary soil gas samples and one field duplicate will be collected from DP009 to meet the requirements of 10 percent for FDs in accordance with the WS#20 of the Site Characterization Work Plan, the JBER Basewide UFP-QAPP, and the UST Procedure manual Table 4. QC samples will be collected on a site-specific basis rather than on a program wide basis.

Louis Howard

5/22/2014

Report or Workplan Review - Other

Responses to ADEC’s comments on the DP009 additional site characterization work plan are acceptable. Please finalize work plan.

Louis Howard

12/30/2014

Update or Other Action

Soil gas addendum received for review & comment.
TCE & PCE were detected in soil gas above the calibrated detection limit (137 & 172 micrograms per cubic meter [µg/m3], respectively) in both the primary & field duplicate sample from location DP009-SV03. TCE was detected at 14,265 µg/m3 in the primary sample & 18,457 µg/m3 in the duplicate sample, & PCE was detected at 1,787 µg/m3 in the primary sample & 2,566 µg/m3 in the duplicate sample at location DP009-SV03.
Location DP009-SV03 is near the former dry well. PCE was observed at concentrations below the calibrated detection limits at two other locations: DP009-SV01 & DP009-SV05. TCE & PCE were not detected at locations DP009-SV02 & DP009-SV04. These soil gas screening results indicate that the former dry well is the source of TCE & PCE in soil & that the contamination is likely confined to the area around the former dry well.
Field screening of oxygen, carbon dioxide, & methane in soil gas from each location indicated that the soil is well oxygenated (18.4 to 21.3 percent) with relatively low carbon dioxide (0.1 to 2.4 percent) & no methane detections.
PCE, TCE, ethylbenzene, toluene, & xylenes were detected in soil gas at DP009-SV03 & DP009-SV06. However, none of the analyte concentrations exceeded ADEC’s residential or commercial/industrial target levels for shallow soil gas. No PCE or TCE degradation compounds (1,1-DCE, cis-1,2-DCE, trans-1,2-DCE, or vinyl chloride) were detected in soil gas samples from DP009-SV03 or DP009-SV06, indicating that degradation of PCE & TCE is not likely occurring.
PCE was detected at levels ranging from 5.93 J µg/m3 to 45.3 µg/m3, & TCE was detected at levels ranging from 2.84 J µg/m3 to 4.21 J µg/m3. The analytical soil gas at DP009-SV03 are several orders of magnitude lower than the soil gas screening results from the same location (see Section 5.1). Benzene was not detected in soil gas at location DP009-SV06 even though soil samples collected in 2013 at the same location contained benzene at 0.039 & 0.145 mg/kg at 0 to 5 feet bgs & 10 to 15 feet bgs, respectively, & 0.46 mg/kg at 20 to 25 feet bgs. Examination of the field documentation (field notes, soil gas probe completion logs, & soil gas sampling logs) for locations DP009-SV03 & DP009-SV06 & discussions with the field team provide no indication of soil gas sample collection error.
The following conclusions were made regarding DP009:
• TCE & PCE were detected in soil gas screening samples at levels up to 18,457 & 2,566 µg/m3, respectively (DP009-SV03 located near the former dry well). Soil gas screening results indicate that the former dry well at DP009 is the source of PCE & TCE contamination at the site. PCE & TCE contamination, while not laterally defined with definitive soil data, appears to be limited to the area surrounding the former dry well. The vertical extent of PCE & TCE contamination was delineated during the 2013 Site Characterization to a maximum depth of 25 feet bgs.
• The risk evaluation completed in 2013 indicated that the vapor intrusion pathway was complete for current industrial & potential future residents at DP009, &, based on modeling of soil concentrations, there was potential risk from exposure to benzene, PCE, & TCE within indoor air. Soil gas samples were collected in 2014, & PCE & TCE were detected at levels up to 45.3 µg/m3 & 4.21 J µg/m3, below ADEC’s residential or commercial/industrial target levels for shallow soil gas. No PCE or TCE degradation compounds (1,1-DCE, cis-1,2-DCE, trans-1,2-DCE, or vinyl chloride) were detected in soil gas samples.
• Comparison of soil gas screening concentrations to soil gas analytical concentrations indicated a discrepancy of up to several orders of magnitude between the results. A reason for the discrepancy was not determined. Given the difference, the results of these soil gas analytical samples should not be used for decision making.
• Soil gas sample results provide no evidence that PCE & TCE are being degraded within the vadose zone at DP009.
• The results of the differential pressure monitoring indicate that there is a constant positive pressure between the office space in the building & the outdoor air. The constant positive pressure in this area of the building & the multiple air exchanges per hour suggest that there is little potential for vapor intrusion & that current exposure to 40-hour-per-week workers via the vapor intrusion pathway is insignificant.

Louis Howard

1/30/2015

Report or Workplan Review - Other

Staff provided review comments on the SC report addendum.
2.0 Site Location and Description
ADEC requests the Air Force elaborate in the text of the document on whether it is occupied and for how many hours per day and how many days per week. ADEC requests the Air Force clarify in text whether there are female workers occupying (short term, intermittent, or full time basis) the building at DP009 due to TCE concerns for indoor air.
4.1 Soil Gas Screening and Sampling
ADEC requests the Air Force to please describe the grade of helium utilized for the leak check procedure. Please clarify if the helium verified to be 99.99% pure.
5.0 Results
ADEC requests the Air Force to discuss in more detail, the potential reasons for the large discrepancy between filed screening and laboratory analytical results. Please elaborate on whether this discrepancy was due to sampling on different days.
5.1 Soil Gas Screening Results
The text states: “TCE was detected at concentration of 14,265 µg/m3 in the primary sample and 18,457 µg/m3 in the duplicate sample, and PCE was detected at a concentration of 1,787 µg/m3 in the primary sample and 2,566 µg/m3 in the duplicate sample at location DP009-SV03”
The 14,265 µg/m3 and 18,457 µg/m3 field screening results for TCE were noted in Table 2 to be “E” flagged which meant the concentration exceeded the calibration range [of the FROG-4000]
EPA’s screening criteria at Commercial/Industrial buildings for indoor air is much lower than the 137 ug/m3 screening level used by JBER: 8.4 µg/m3 for Short-term noncancer, 0.88 µg/m3 for Chronic noncancer (HQ of 0.1) and 3.0 µg/m3 for Cancer risk of 1x10-6 (Table 1. EPA Region 10 Recommended Media Concentrations of TCE in Standard Environmental Media for Use at Superfund and RCRA Waste Sites). The soil gas sample results taken from outside surrounding a building may be quite different than indoor air samples taken inside due to a number of factors.
The elevated TCE field screening FROG-4000 result from DP009-SV03 of 18,457 µg/m3 is of concern to ADEC even if “Soil gas screening results are not compared to screening levels. The results were used to determine presence or absence and a rough order of magnitude to assess the distribution of PCE and TCE in the subsurface.” One order of magnitude lower result of 1,846 µg/m3 would still be a high soil gas sample result when compared to EPA’s December 2012 TCE Not-To-Be-Exceeded concentrations in Table 1.
6.1 Conclusions
The text states: “The following conclusions were made regarding DP009:
• TCE and PCE were detected in soil gas screening samples at concentrations up to 18,457 and 2,566 µg/m3, respectively (DP009-SV03 located near the former dry well). Soil gas screening results indicate that the former dry well at DP009 is the source of PCE and TCE contamination at the site. PCE and TCE contamination, while not laterally defined with definitive soil data, appears to be limited to the area surrounding the former dry well. The vertical extent of PCE and TCE contamination was delineated during the 2013 Site Characterization to a maximum depth of 25 feet bgs.
• Comparison of soil gas screening concentrations to soil gas analytical concentrations indicated a discrepancy of up to several orders of magnitude between the results. A reason for the discrepancy was not determined. Given the difference, the results of these soil gas analytical samples should not be used for decision making.”
ADEC concurs with the recommendations and requests the Air Force consider obtaining both sub-slab soil gas samples and indoor air samples from Building 986 in addition to definitively define the lateral extent of TCE and PCE in soil with soil samples. ADEC requests the EPA, ADEC and JBER remedial project managers meet and discuss the transfer of DP009 from the Two-Party Agreement back into the CERCLA process under the Fort Richardson Federal Agreement.

Louis Howard

2/25/2015

Update or Other Action

Staff reviewed responses to comments and the redline version of the document. The changes made are acceptable and the document may be finalized.

Louis Howard

9/16/2016

Update or Other Action

Supplemental work plan received for review to address the groundwater sampling, institutional controls (IC) inspection, and landfill cap inspection activities associated with the 2016 Long Term Monitoring (LTM) at the Joint Base Elmendorf-Richardson (JBER), Sites PL081, CG551, ST408, CG530, SO510, SS522, SO507, SS418, TS003, CG543, CG529, TU107, ST048, CG509, SO508, SO549, AT035, AT029, SS019, and DP009.
As a requirement of the 2016 Environmental Long Term Monitoring contract, the following work shall be performed at JBER Site DP009:
? Perform IC inspection

Louis Howard

3/22/2017

Update or Other Action

2016 Draft Report for Remedial Action Operation and Land Use/Institutional Control at JBER received for review and comment.
Land use controls are required at the site since contamination is present at concentrations that
exceed ADEC Cleanup Standards, which does not allow for unrestricted use. This site has been
added to the JBER-R FFA for further contamination determination.
The inspection of Site DP009 revealed no evidence of ground disturbance at this site. Revegetation
appeared to be occurring and the monitoring wells located at the site were observed to be in good condition. An aboveground storage tank with associated secondary containment was also observed onsite. No warning signs relevant to the area of concern were observed. Photographs 1 through 3 in Photograph Log A16 present the general condition of Site DP009.
See site file for additional information.

Draft Uniform Federal Policy—Quality Assurance Project Plan (UFP-QAPP) presents the proposed
objectives, methods, and procedures for limited field investigations of Sites AT029, DP009, SS019, and SS120 received for review and comment. the remedial investigation needs to achieve the following objectives:
• Evaluate the VI pathway. This includes conducting two rounds (heating season and shoulder
season) of indoor air, outdoor air, and subslab soil gas sampling at Building 986, followed by
performing a new building survey at Building 986 with each of the two rounds of sampling. Indoor to subslab differential pressure will be measured during VI sampling (Section 17.2). These sampling events are to assess whether the VI pathway is complete and significant at Building 986.
• Define the lateral extent of soil VOC contamination. This will include subsurface sampling soil both inside and outside the contaminated soil area.
See site file for additional information.

Louis Howard

2/26/2018

Report or Workplan Review - Other

Staff reviewed and commended on the draft UFP-QAPP LFI and had the following comments: include all the daughter products of PCE in the analysis of indoor air, outdoor air, and sub-slab soil gas. The analysis and reporting of the following per 8270C-SIM (in addition to PAHs):
3,3-dicholorbenzidine, 4-chloroaniline, bis(2-chloroethyl)ether, hexachlorobeznene, hexachlorobutadiene, hexachloroethane, nitrobenzene, N-Nitrosodimethylamine, N-Nitrosodi-n-propylamine, N-Nitrosodiphenylamine, and pentachlorophenol. Due to contracting issues, the number of samples per boring was limited to two (2) per boring. Neither ADEC nor EPA project managers were involved in scoping the work plan prior to August 3, 2017 meeting with AFCEC and their contractor. The number of samples were already finalized in contracting mechanisms and not subject to change.
Nevertheless, ADEC highly suggests that three (3) soil samples per boring be taken to equal 18 total soil sample results which would meet the desired number of observations recommended by ProUCL (15-20). If three soil samples per boring were conducted, soil sampling would be from 15’ bgs, the highest field screening result and the bottom of the soil boring.
See site file for additional information.

Louis Howard

Contaminant Information

Name

Level Description

Media

Comments

DRO

Between Method 2 Migration to Groundwater and Human Health/Ingestion/Inhalation

Soil

Control Type

Type

Details

Land Use Plan / Maps / Base Master Plan

Post maps are regularly updated to show all areas affected by ICs. Copies are provided to each directorate, activity and tenant organization. To ensure the effectiveness of ICs, all units and tenants are informed annually of ICs on contaminated soils and groundwater in effect at the Post. Where ICs are applicable, land use restrictions shall be incorporated into the lease or memorandum of agreement for any organization, tenant, or activity as appropriate.

Requirements

Description

Details

Excavation / Soil Movement Restrictions

All organizations conducting activities on Ft. Richardson must comply with institutional controls (ICs) which are applicable to all known or suspected contaminated sites.
ICs include: land use restrictions & limiting excavation depths. ICs are in effect at both CERCLA and Two-Party Agreement (UST & NON-UST) sites. Implementation of ICs: Organizations must obtain an excavation clearance request for all activities that disturb soil > 6” in depth. To ensure the effectiveness of ICs, all units and tenants are informed annually of ICs on contaminated soils and groundwater in effect at the Post.

Missing Location Data

Because the GIS location data for this site has not been entered, we cannot direct you to its position on the map. Click "Continue" to proceed to the Contaminated Sites Web Map or "Close" to return to the site report.